KBLI 2025 and the June 2026 OSS Deadline: What Every PT PMA Must Do

The Signal: a Date in the Calendar Almost Nobody Has Looked At

On 18 June 2026 a deadline expires that affects every foreign company operating in Indonesia, and that has largely gone unnoticed outside local law firms. That day marks the end of the mandatory integration of the new KBLI 2025 classification into the OSS (Online Single Submission) system, and with it the transition period for already-incorporated companies — including foreign-owned PT PMAs — to adapt their business activity codes to the new table.

This is not a minor formality. The KBLI code is the foundation the entire licensing regime rests on: it determines the risk level of the activity, which permits a company can obtain, and how the OSS-RBA system processes each application. If the code has not been migrated to the 2025 version when the deadline passes, the NIB (Business Identification Number) can be flagged or blocked — and with it the ability to renew licences, amend permits, or apply for new authorisations.

For the international investor operating — or planning to operate — a rental villa in Indonesia through a PT PMA, this is not bureaucratic trivia. It is an operating condition. The structure can be perfectly incorporated and still be paralysed by an outdated code.

What Has Actually Changed

Three regulations have to be fitted together to understand the June deadline.

1. PP 28/2025: the New Risk-Based Licensing Framework

Government Regulation PP No. 28/2025 on Risk-Based Business Licensing came into force on 5 June 2025, replacing the earlier PP No. 5/2021. According to analysis from firms such as ATD Law (in association with Mori Hamada) and Herbert Smith Freehills, the regulation aims to accelerate and make approvals more predictable, but in exchange raises the bar for ongoing compliance by both foreign and domestic companies. The regulation extends risk-based licensing to seven additional business sectors.

2. KBLI 2025 Replaces KBLI 2020

The new Indonesian Standard Industrial Classification (KBLI 2025) replaces the 2020 table. The number of codes rises from 1,348 to 1,417 entries, according to reports from Emerhub and ASEAN Briefing. Each code is mapped to a risk category — low, medium-low, medium-high or high — and that level determines whether the activity requires only the NIB or also standard certificates and operational licences. For tourist accommodation, the reference codes remain 55193 (villa rental) and 55110 (hotels, depending on scale).

3. The Deadline: 18 June 2026

The deadline originates in BPS Regulation No. 7 of 2025, promulgated in December 2025. Its Article 5 requires all existing KBLI users to complete the adjustment to KBLI 2025 within six months of promulgation. That places the cut-off on 18 June 2026 — the same day the integration of KBLI 2025 into the OSS must be completed, according to Schinder Law Firm and the firm legalindonesia.id.

The operational distinction matters:

• Already-incorporated companies (including PT PMAs): have the transition period until 18 June 2026 to synchronise their codes.
• New companies: have no transition period. Any articles of association, NIB application, or OSS filing submitted in 2026 must already reflect KBLI 2025 from the outset.

What It Means for the Foreign Investor with a PT PMA

The risk plays out as a familiar sequence. If the KBLI code is not migrated when the deadline passes, the firms consulted report that the NIB is flagged or blocked in the OSS system. From that point, no permits can be renewed, amended, or applied for until the codes are synchronised to the 2025 version. Add OSS-RBA data discrepancies and complications during regulatory inspections or audits.

The precedent is not theoretical. According to sector consultancy data, in 2025 alone more than 260 foreign-owned companies lost their licences over compliance issues. A misassigned or outdated code can, in practice, leave the operation suspended at the very moment the investor needs to renew the tourism TDUP or process the certificate of occupancy.

For a rental villa operated via PT PMA, the practical implications are three:

1. Check the code before anything else. The first step of 2026 is neither commercial nor fiscal: it is to verify in the OSS that the company's KBLI has been migrated to the 2025 version and still correctly describes the real activity (villa rental, tourist accommodation management). 2. Anticipate the dependency chain. The NIB underpins the TDUP, the TDUP underpins presence on OTA platforms, and all of it underpins revenue. A blockage upstream propagates downstream. 3. Treat compliance as recurring maintenance, not a one-off act. PP 28/2025 shifts the weight of compliance from the moment of incorporation to ongoing operation. The PT PMA well structured in 2024 is not exempt from reviewing its code in 2026.

Lombok in This Context: the Advantage of Entering on the New Table

The framework is national. OSS, NIB, KBLI and PT PMA apply equally in Bali, in Lombok, and in any province of the archipelago. What changes between territories is not the rules, but the volume of pre-existing structure that has to be reorganised.

Whoever enters the market now, incorporating a PT PMA from scratch in 2026, does so directly on KBLI 2025. There is no 2020 code to migrate, no old filing to synchronise: the system requires the new table from the first step, which by design removes the June deadline risk for new projects.

That is a structural difference rather than a marketing argument. An investor structuring a Lombok project today starts with licensing aligned to current regulation, carrying no regulatory debt to clear. In a market with less built mass under informal structures, the cost of doing things right from day one is substantially lower than correcting them later. This is not "Lombok versus Bali": it is the difference between building on the new table or having to rewrite the old one against the clock.

Frequently Asked Questions

I have a PT PMA incorporated in 2024. Do I need to do anything before 18 June 2026? Yes. Even if the company is correctly incorporated, its KBLI code should be verified and, where applicable, migrated to the 2025 version within the transition period. The adjustment is made through the OSS portal. It is worth confirming with the notary (PPAT) or adviser managing the company.

What happens if I do not migrate in time? According to the firms consulted, the NIB can be flagged or blocked in the OSS. That prevents renewing, amending, or applying for permits until the codes are synchronised, and creates data discrepancies that complicate inspections and audits.

I am going to incorporate a new PT PMA in 2026. Does the transition deadline affect me? Not in the same way. New companies have no transition period: any filing submitted in 2026 must use KBLI 2025 from the start. In practice, this simplifies the process for someone entering now.

Does the KBLI code change the taxes I pay? The KBLI does not set the tax rate, but it does determine the risk level of the activity and, with it, which licences and certificates are required. Tax obligations (PBJT, VAT, CIT) follow their own regime and should be reviewed case by case with an Indonesian tax adviser.

Risks and Caveats

This analysis is based on public information as of June 2026 and does not constitute legal, tax, or financial advice. Some points the investor should weigh explicitly:

• Framework in rollout. PP 28/2025 and the KBLI 2025 integration are ongoing reforms; clarifying circulars and operational adjustments should be expected through 2026 and 2027 that may alter deadlines or procedures.
• Reliance on the local adviser. Code migration and NIB maintenance are not handled correctly without an accredited notary (PPAT) and a specialist adviser. The quality of the provider determines the outcome.
• Code mapping is not always direct. Moving from KBLI 2020 to 2025 is not a cosmetic change: some activities are reclassified and the equivalent code may not be obvious, which calls for professional judgement.
• Currency exposure. Investments are denominated in IDR; the EUR or USD investor bears currency risk on entry, returns, and exit.
• Operational variability. Regulatory compliance is a necessary condition, not a sufficient one: occupancy, management, and the macro cycle still determine the economic result.

The regulatory information in this article reflects public rules as of June 2026 and may change. Real estate investment carries risks, including regulatory changes, market fluctuations, and occupancy variability. Verify every step with Indonesian legal and tax advisers before acting.

What to Read Next

• Villa Compliance in Indonesia 2026: the End of the Amateur Era — The context of the regulatory tightening and Bali's March 2026 deadline.
• Indonesian Property Law for Foreigners — A guide to PT PMA, Hak Pakai, and tax obligations.
• Lombok vs Bali: Where to Invest in 2026? — A comparison of prices, yields, and infrastructure.

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Sources consulted:

• Schinder Law Firm — "Implementation of KBLI 2025 in the OSS System: Timeline, Adjustment Requirements, and Legal Implications" (2026).
• ATD Law in association with Mori Hamada — "Update on Indonesia's Business Licensing Regime: Key Changes under GR 28/2025" (2025-2026).
• Herbert Smith Freehills Kramer — "New Indonesian Investment Rules 2025" (November 2025).
• ARMA Law — "Navigating Indonesia's New Licensing Landscape: General Points from GR 28/2025" (2025).
• ASEAN Briefing — "Business License Classification in Indonesia's Risk-Based Licensing (RBA) System" (2026).
• Emerhub — "Indonesia's New Business Classification Regulation (KBLI 2025): Companies Must Update Licensing Data by June" (2026).
• legalindonesia.id — "KBLI 2025 Transition in Indonesia: What Businesses Need to Do Before June 18, 2026" (2026).
• Business Hub Asia — "How to Navigate KBLI 2025 Adjustments Before the June 2026 Deadline" (2026).
• Government Regulation PP No. 28/2025 and BPS Regulation No. 7 of 2025.